Wow.  This newest First DCA decision is a doozy, one that alot of us on the defense side have argued-to no avail-for a long time.  That is until now. 

In Fast Track Framing v. Marando Homes, the Court found that if a Claimant is paid cash under the table, and does not report those wages to the IRS as taxable income, the money will not be counted as “wages” and therefore cannot be calculated in Claimant’s average weekly wage (AWW).  The AWW is used to determine how much Claimant is paid in wage loss benefits when she is taken off work.   So, if a Claimant is earning unreported cash, then his AWW is $0.00.